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Ethics and compliance

How we live our principles

Leading by example

The AG真人计划 Ethics and Compliance Programme seeks to ensure that the company's business practices conform to applicable laws, regulations and ethical business principles, as well as developing a culture of integrity.

Commitments and standards

Our commitment

Over the years, AG真人计划 has earned the trust of passengers, customers, operators and other stakeholders through the quality and safety of our products. To fully serve our communities and thrive in the future, our聽commitment to business integrity聽must be just as robust 鈥 this means聽conducting our business ethically聽and based on聽AG真人计划 Values, and聽in compliance with all laws and regulations.

Our goal is to be known as a company with 鈥榠ntegrity inside鈥: integrity in its people, partners and suppliers.聽

As part of this commitment, AG真人计划 supports the principles of the聽UN Global Compact聽and IFBEC's聽Global Principles of Business Ethics聽which set a benchmark for high ethical standards globally.

AG真人计划 is also committed to the FX Global Code, a joint initiative between major central banks and private sectors participants to enhance integrity of the foreign exchange markets.

Join me in focusing on what really matters: rejecting bribery and corruption, preserving our integrity and embracing our values for the purpose of serving the best interests of our great company AG真人计划.

Guillaume Faury 鈥 CEO AG真人计划

Ethics and compliance
Ethics and Compliance 08 June 2017

Ethics and compliance

Customers, passengers, operators and stakeholders worldwide trust in the quality and safety of AG真人计划' products.

Read more

Our standards

The foundation for integrity at AG真人计划 is our聽Code of Conduct (CoC).聽 The Code is intended to聽guide daily behaviour聽and help employees resolve the most common ethical and compliance issues that they may encounter.

The Code of Conduct applies to聽all employees, officers and directors of AG真人计划聽as well as entities that we control. Third party stakeholders whom we engage are also expected to adhere to AG真人计划 Code of Conduct in the course of performing work on our behalf.

AGM 2019
Guillaume Faury, Chief Executive Officer, AG真人计划.


Programme and risk

Our programme

While our Code of Conduct provides a useful starting point, they cannot answer all questions, nor are they sufficient to ensure that AG真人计划 complies with the myriad legal requirements applicable to its business.聽Because of this, we have worked over the past several years to develop an Ethics and Compliance programme that is structured around three key risk areas: Business Ethics/Anti-Corruption Compliance, Export Compliance and Data Protection Compliance.

Each of these areas are in turn supported by dedicated compliance policies and a team responsible for their implementation, together with the identification and proposal of new measures to adapt to a constantly evolving regulatory landscape.聽

Improving our programme聽is a constant and ongoing process, not only in the area of Business Ethics/Anti-Corruption but across the ethics and compliance spectrum more generally.

Anti-corruption compliance

AG真人计划 rejects corruption聽of any kind, whether public or private, active or passive. This means that neither we, our employees or third parties acting on our behalf may offer, promise, give, solicit or receive 鈥 directly or indirectly 鈥 money or anything of value to or from a government official or someone in the private sector in order to obtain or retain business or secure some other improper advantage.

Our anti-corruption policy聽summarises our stance of zero tolerance. It also refers to some of the specific directives we have adopted to address聽key anti-corruption risk areas, such as the engagement of third parties, gifts and hospitality exchange and the making of sponsorships and donations.

More broadly, Business Ethics at AG真人计划 also covers other areas such as conflicts of interest, anti-competitive conduct, insider trading, fraud, etc., while also complementing the AG真人计划 Corporate Responsibility programme which focuses on managing the social and environmental impacts of AG真人计划鈥檚 operations.

Conflicts of interest

We do not allow personal interests to interfere, or appear to interfere, with our ability to make fair and objective decisions when performing our jobs in the best interest of AG真人计划.

AG真人计划 has implemented a directive requiring employees facing a situation that represents or may represent a conflict of interest with regards to their activities with or within AG真人计划 should proactively declare it to the Ethics & Compliance team. Examples include, among others, having a financial interest or directorship in a third party, an outside employment or a side business, or, for example, having a relative who is a public official with decision-making power that could affect AG真人计划.

Failing to declare and manage properly a conflict of interest situation may have negative consequences for individuals and for AG真人计划.

Gifts and Hospitality

Gifts or hospitality shall not be extended as a way to improperly influence a business decision or gain an undue competitive advantage.

The giving and receiving of any gifts or hospitality are regulated by an internal AG真人计划 Internal policy and are subject to recording and pre-approval into a digital approval tool depending on their value.

Before offering or accepting any gifts or hospitality, we must ensure that (i) it is lawful, (ii) the value is reasonable and (iii) it is allowed under AG真人计划 internal policies and standards.

Extra caution must be taken when interacting with government officials, for which specific compliance pre-approval is required as set forth in the applicable AG真人计划 policy.

Sponsorship, membership and donations

AG真人计划 has a Sponsorships, Donations and Corporate Memberships Directive that applies to all employees. The Directive incorporates mandatory recording for all projects irrespective of their values and sign-off requirements by Ethics & Compliance for projects over certain financial values, or where E&C 'red flags' are identified.

All Sponsorships, Donations and Corporate Memberships entered into by AG真人计划 must:

  • Have a legitimate charitable, societal, professional trade or promotional purpose, consistent with AG真人计划鈥 global strategy, priorities and values;
  • Comply with all applicable laws;
  • Be made to reputable organisations or beneficiaries;
  • Be properly recorded.

The Sponsorship, Donations and Corporate Membership Directive also applies to political contributions.

Intermediaries, agents

AG真人计划 has implemented a 鈥淏usiness Development Support Initiative鈥 directive for the approval and monitoring of commercial intermediaries / agents, requiring them to undergo an enhanced Ethics & Compliance due diligence background check and multi-level managerial approval prior to engagement. As part of the process, information gathered directly from the potential intermediary/agent is corroborated by AG真人计划鈥 own in depth thorough research activities, e.g. to confirm/establish the ultimate beneficial ownership of the intermediary. In the event where AG真人计划 identifies red flags or risks that cannot be properly mitigated, in particular questions concerning ultimate beneficial ownership, the company has and will refuse new engagements and terminate existing engagements with the third party.

Commercial intermediaries鈥 activities are monitored on a regular basis throughout the entire life of the relationship. Payments require approval from different functions including Ethics & Compliance and Finance, and are processed only upon reception of satisfactory and detailed activity reports.

AG真人计划 systematically requires inclusion of an anti-corruption clause in its contracts with intermediaries, which includes a termination right for AG真人计划 in case of failure by the latter to adhere to anti-corruption or other standards. Incentives schemes for agents are designed and calculated in such a way to promote ethical behaviours and discourage corrupt practices.

Lobbyists and special advisors

AG真人计划 is committed to ensuring that any Lobbying Activity is done in compliance with all applicable laws and its Anti- Corruption Programme.

Third parties conducting lobbying activities must undergo a thorough due diligence check and abide by the detailed guidelines set in the Lobbyist & Special Advisors Due Diligence Directive.

Lobbyists & Special Advisors must act with honesty, integrity and transparency at all times and work closely with the relevant AG真人计划 Ethics & Compliance and Government Relations teams.

Invoices will be paid only upon reception of detailed activity reports and invoices which should include accurate and factual information about the activities carried out.

Ethics & Compliance regularly audits these third parties.

Supplier compliance review

Complementing the specific processes applicable to commercial intermediaries, lobbyist & Special Advisors, Sponsorships & Donations, the Ethics & Compliance team conducts screening on the entire supplier base of the group.聽

Consequently, all suppliers聽undergo an automated initial screening and ongoing monitoring through the AG真人计划 Supplier Screening Tool.

The third-party due diligence is managed by the Ethics & Compliance team to ensure a full segregation of duty with the Procurement team, which itself maintains oversight of all supplier relationships.

Prevention of corruption related to M&A, JVS and similar transactions

AG真人计划 has implemented a Directive to ensure that corruption risks associated with potential M&A, JV and similar transactions are detected, assessed and mitigated.聽

The Directive incorporates a number of milestones which are reviewed from a compliance perspective at each stage of the transaction. For example, the Directive sets out the requirement for AG真人计划 to establish a potential JV鈥檚 ultimate ownership, understand its track record with regard to anti-corruption initiatives, and scrutinise key individuals鈥 historical business activities.

In addition, the Directive provides for extra requirements such as the right to conduct periodic audits on a JV's activities.

The Directive also requires that AG真人计划 is able to terminate a JV following breaches of anti-corruption representations and warranties in the JV agreement.

Offset contracting

As part of its mission to support sales campaigns and contract execution in certain countries, AG真人计划 may enter into Offset related agreements.

Offset Transactions carried out by, or on behalf of AG真人计划, must comply with the company's policies and all the applicable laws, which include but are not limited to, anti-corruption, export controls and local procurement laws and regulations.

All Offset Third Parties must be reviewed from a compliance perspective prior to entry into any binding agreement or transaction.

The depth of the due diligence will depend on the level of risks implied by the Offset agreement (Country risk; Operational risk; Commercial relation type: supplier; JV partner; Consulting services etc.)

The company has implemented a dedicated procedure for the compliance review of offset third parties and projects. As for intermediaries and JVs, this includes due diligence steps to ensure the legitimate business rationale of investments, checks to confirm/establish the ultimate beneficial ownership of third parties, etc. A central business team in turn has oversight over all approved offset projects and commitments, working closely with the Ethics & Compliance team on proposed new engagements as needed.

Anti-Money Laundering

AG真人计划 conducts business only with reputable Customers, who are involved in legitimate business activities and whose funds are derived from legitimate sources.

To ensure that its Customers do not present Money Laundering/Terrorism Financing risks, AG真人计划 has implemented a Directive to perform risk-based due diligence depending on the level of Anti-Money Laundering/ Counter-Terrorism Financing risk induced by its prospective Customer. This due diligence is also known as the Know Your Customer (KYC) process.

Such due diligence includes identifying and understanding the identities of individual ultimate beneficial owners and the Customer's source of wealth or funds.

The KYC due diligence is updated periodically on a risk basis and in case of significant changes in the relationship or activity.

The process incorporates an enhanced level of due diligence to be performed where a prospective customer resides in a FATF-designated High-Risk or Non-Cooperative Jurisdiction, or where other red flags are identified. In the event that red flags are unable to be mitigated at the conclusion of the Divisional Customer Due Diligence Process, there will be an escalation to the Group level for additional consideration and recommendation.

Monitoring, controls and audits

The Ethics & Compliance organisation is charged with oversight and monitoring of the Ethics & Compliance Programme to ensure that it is being implemented effectively. Periodic controls on key processes are performed and reports provided to the AG真人计划 Executive Committee and Ethics & Compliance Committee of the Board of Directors, including recommendations to strengthen the Ethics & Compliance programme where necessary.

In addition, the Corporate Audit & Forensic Department conducts periodic (at least annual), independent audits of AG真人计划 compliance processes to assess the effectiveness of internal controls and procedures and allow AG真人计划 to develop action plans for strengthening such controls.

Export compliance

Each of the countries in which AG真人计划 does business has controls on the export and transfer of its goods and technologies that are considered to be important to national security and foreign policies. As a global enterprise, it is AG真人计划鈥 responsibility to respect and comply with each of these controls. Our Export Compliance Directive defines our policies, processes and organisation to ensure compliance with all relevant export control laws and regulations.

Data protection compliance

AG真人计划 is required to handle personal data in accordance with applicable data privacy laws at national, European and international level. In doing so, AG真人计划 seeks to apply a consistent approach, by setting data security standards for personal data processing in line with global best practice. This is embodied in part by our Binding Corporate Rules, which provide a consistent level of protection for various personal data throughout AG真人计划.

Procurement compliance

AG真人计划 suppliers must comply with all applicable laws and regulations of the countries in which operations are managed or services provided. In addition, wherever suppliers are located, all business should be conducted in a manner compatible with the AG真人计划 Supplier Code of Conduct. Please see below all language versions available:

Suppliers are also expected to cascade these principles through their own supply chain.聽

Organisation and culture

Our organisation

Our聽Ethics and Compliance organisation聽is part of the Legal Department under the聽ultimate responsibility of the AG真人计划' General Counsel. The aim is to provide strong governance throughout the company with the global presence of qualified compliance officers who ensure the compliance programme is implemented in the different functional and operational areas.

They do this in close cooperation with our employees and management, who are expected to聽lead with integrity by example聽and take responsibility for compliance within their scope of activity.

Our awareness and training

While the Tone at the Top and leading by example are critical for the success of the Ethics & Compliance Programme, it is equally important to ensure that employees and Directors receive the right level of training and awareness around the key Directives.

AG真人计划 aims to educate its employees about the standards of conduct that apply to their jobs and the potential consequences, including on anti-corruption.

All AG真人计划 employees receive Ethics & Compliance training including on Anti-Corruption and are required to take at least one ethics & compliance e-learning per year. Additionally, depending on the functions, the country and the level of risk implied by their role, some employees may be selected to attend enhanced and tailored face to face Anti-Corruption training.

Speak Up

AG真人计划 is committed to maintaining a Speak Up culture by promoting an open and trusting dialogue with employees at all levels.

All employees are encouraged to express their views, defend their opinions, and point out unacceptable behaviour鈥攅specially behaviour that violates our Code of Conduct. Employees can raise concerns to their line manager, their Human Resources Business Partner, to a Legal & Compliance representative, or through the AG真人计划 鈥淥penLine鈥 (

The OpenLine is a channel through which employees and other stakeholders may submit an alert securely and confidentially or anonymously. Alerts could relate to our Code of Conduct, policies and standards, or to compliance with applicable laws or regulations. The use of the OpenLine is entirely optional and voluntary, and there will be no consequences for employees who do not use the system.

AG真人计划 protects those who Speak Up and raise concerns appropriately and in good faith; we do not retaliate against anyone who raises a concern, or against those who assist in investigations of suspected violations. Retaliation can take many forms, both direct and indirect, including: harassment, exclusion from meetings, sanction, dismissal, or other discriminatory measures, in particular related to compensation, profit-sharing, free share awards, job classification, performance reviews, promotion, training, transfers, contract renewal, etc.聽


AG真人计划 takes seriously its responsibility to investigate potential instances of misconduct, whether detected in the normal course of business, via the AG真人计划 OpenLine or from any other source.

聽AG真人计划 has developed a dedicated investigations procedure to ensure that these investigations are conducted in a consistent and professional manner in accordance with company standards and relevant laws.

聽Investigations are closely monitored by the investigation team to ensure a timely resolution and documentation of the investigative work performed.

聽In the event a misconduct is confirmed, AG真人计划 considers not only appropriate disciplinary action for the employees involved, but also engages in a root cause analysis of the misconduct.

Passion for progress

Passion for progress

Interactive Annual Report 2018

the Ethics and Compliance team
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